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NOTICE OF DISCOVERY AND INSPECTION Notice for Discovery and Inspection for Insurance Disclosure

Document ROSA GUZMAN v. TOMPKINSVILLE CAR SERVICE INC. et al, 151261/2024, 18 (N.Y. Sup. Ct., Richmond County Aug. 5, 2024)
PLEASE TAKE NOTICE that Plaintiff, by her attorneys, AJLOUNY INJURY LAW hereby demands that, within twenty (20) days after service hereof, Defendant, TOMKINSVILLE CAR SERVICE INC. serve upon the office of the undersigned, the following:
If, after investigation, no such excess liability/”umbrella” policies are found to exist, so state in a sworn reply to this demand.
PLEASE TAKE FURTHER NOTICE, that failure to promptly disclose coverage is a violation of New York Insurance Law §2601(a)(6).
PLEASE TAKE FURTHER NOTICE, that failure to produce said documents in a timely manner will result in a motion for appropriate relief.
By: Michael Levitz, Esq. -Attorneys for Plaintiffs- 320 Old Country Road, Suite 205 Garden City, New York 11530
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EXHIBIT(S) - 3 Google Photos

Document ROSA GUZMAN v. TOMPKINSVILLE CAR SERVICE INC. et al, 151261/2024, 15 (N.Y. Sup. Ct., Richmond County Aug. 1, 2024)
15 RichmondTer - Google Maps Google Maps 15 Richmond Ter NewYork Google Street View Oct 2022 See more dates Image capture: Oct 2022 ©2024 Google
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STATEMENT OF MATERIAL FACTS Statement of Material Facts

Document ROSA GUZMAN v. TOMPKINSVILLE CAR SERVICE INC. et al, 151261/2024, 12 (N.Y. Sup. Ct., Richmond County Aug. 1, 2024)
STATEMENTOFMATERIALFACTSPURSUANTTOUNIFORMRULE202.8-g ROSAGUZMAN,by and through her attorneys, AJLOUNYINJURYLAW, Plaintiff, submits this Statement of Material Facts pursuant to Rule 202.8-g, with respect to which there are no issues to be tried, with citations to the evidence in support of the Plaintiff's motion for summary judgment and hereby sets forth the following: commenced this lawsuit on June 24, 2024, as a result of a motor vehicle 1.
That on July 2, 2024, the Defendant interposed accident occurred on Richmond Terrace, 3.
That this motor vehicle at or near its intersection with York Avenue, County of Richmond, NewYork.
That the Defendant, was making a left struck the bicyclist Plaintiff.
That liability the Plaintiff makes the herein motion seeking summary judgement on the issue of as she is not at the accident.
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AFFIRMATION Affirmation of Service (Amann)

Document ROSA GUZMAN v. TOMPKINSVILLE CAR SERVICE INC. et al, 151261/2024, 9 (N.Y. Sup. Ct., Richmond County Jul. 31, 2024)
is over 18 years of age and resides at 11:11 AMat 24 HAMILTONSTREET, STATENISLAND, NY10304, Deponent served the within That on 7/26/2024, Summonsand Verified Complaint with Notice of Commencementof Action Subject to Mandatory Electronic Filing with the index number and the filing date of the action were endorsed upon the face of the papers so served herein.
referred , a true copy of each to the door of said premises which is subjects dwelling house (usual By affixing place of abode) within the state.
Deponent was unable with due diligence or person of suitable age and discretion to find subject thereat on: having called thereat Attempts of service madeon 06/26/2024 3:33 PM, 07/02/2024 2:28 PM, 07/09/2024 7:59 PM, 07/10/2024 3:12 on 7/26/2024 11:11 AM. PM,7/26/2024 11:11 AM, with service effectuated of the subject was confirmed by DMVverification 623N.Y.S.2d932.
A description the residence In addition, area is as follows: Brown wood door 2 locks yellow walls steps to door ifs surrounding of the door and .luly 26 2024 I affirm on this day , under the penalties of under the laws of NewYork, which mayinclude a fine or imprisonment, perjury the foregoing is true, and I understand that this document maybe filed in that an action or proceedi court of law.
Lic # JoblD 2104295 2436977 Client's File No.: INTERCOUNTYJUDICIAL SERVICES, LLC, 6851 JERICHo TURNPIKE, SUITE 180, SYOSSET,NY11791 LICENSE# 1371771 UNITEDPROCEssSERVICE
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